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his name, $1,740 in withholding, and the year 1997 in the
numerous blank spaces on the form.
For 1997, respondent concluded that petitioner had taxable
income of $11,041 and owed taxes of $1,654. Respondent imposed a
section 6702 frivolous return penalty of $500. Petitioner had
$1,740 of income tax withheld. Respondent applied an overpayment
credit of $86 (the excess of $1,740 over $1,654) to the section
6702 penalty.
Thereafter, on August 10, 2000, respondent issued petitioner
a Final Notice--Notice of Intent to Levy and Notice of Your Right
to a Hearing (the notice of intent to levy) for 1997.3 The type
of tax is listed as “CIVPEN”. There is an assessed balance of
$414 and statutory additions of $64, for a total amount due of
$478. The notice of intent to levy is addressed solely to “Jason
R Henderson”.
On February 25, 2002, petitioners attended a hearing with
respondent’s Appeals Office with respect to the notices of intent
to levy for 1997 and 1999. On April 4, 2002, respondent issued
the notices of determination for 1997 and 1999.4 The 1997 notice
of determination is addressed solely to petitioner “Jason R
3 Respondent also issued a notice of intent to levy for
1999. It is not part of the record in this case.
4 The notice of determination for 1999 is addressed to both
“Jason R & Geanie Y Henderson.” It indicates that the “Tax
Type/Form Number” is for Form 1040 taxes.
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